On April 3, 2012 the Environmental Protection Agency (EPA) is due to finalize national emission standards to limit some of the harmful air pollutants discharged from a variety of oil and gas activities. As Environmental Defense Fund (EDF) has noted in past blogs, leaks, venting and flaring of natural gas from oil and gas activities contribute to ground-level ozone ("smog") and toxic air pollution. As proposed, EPA's standards would reduce volatile organic compounds that contribute to smog by 25% and hazardous air pollutants by 30%, through the implementation of proven and highly cost-effective practices and technologies.

Extensive oil and gas development in parts of rural Wyoming and Utah, where little other industrial activity occurs, has led to dangerous ozone levels, higher than those recorded in some of the most heavily polluted cities. Last year, families in Wyoming’s Upper Green River Basin suffered over forty days in which ozone concentrations exceeded the current health standard. In Utah’s Uintah basin, residents experienced twice this number of unhealthy ozone days, with one monitor located in Ouray recording forty exceedances alone.

In 2009 then Governor of Wyoming Dave Freudenthal requested EPA designate counties within the Upper Green River Basin as out of attainment with the current ozone health standard explaining the link between natural gas emissions and the serious ozone problems:

"The State of Wyoming is also challenged by the need to reduce emissions from the natural gas industry which has not traditionally been regulated for ozone nonattainment problems….Therefore, the Wyoming Department of Environmental Quality (WDEQ) has already identified the sources that require controls such as drill rigs, pneumatic pumps, dehydration units and small heaters."

EPA in turn concluded “[t]he [Wyoming] AQD’s analysis provided with its recommendation shows that elevated ozone at the Boulder monitor is primarily due to local emissions from oil and gas development activities: drilling, production, storage, transport and treating of oil and natural gas.”

In Colorado and Texas, smog-forming emissions from the oil and gas industry have exceeded other major sources of pollution such as vehicles. In 2008, the Colorado Department of Public Health and Environment concluded that the smog-forming emissions from oil and gas operations exceeded vehicle emissions for the entire state. Similarly, a 2009 study found that summertime emissions of smog-forming pollutants from oil and gas sources in the Barnett Shale were roughly comparable to emissions from all of the motor vehicles in the Dallas Fort-Worth area.

Oil and Gas Activities Emit Benzene-A Known Carcinogen-and other Air Toxics

Venting, flaring and equipment leaks also emit hazardous air pollutants or air toxics, including hydrogen sulfide, formaldehyde and benzene into the environment. Elevated levels of benzene have been detected near gas production sites in Texas and Colorado. In 2010 the Texas Commission on Environmental Quality (TCEQ) measured acute concentrations of benzene that exceeded the state’s health-based risk levels at two exploration and production sites in the Barnett Shale in Texas. Research based on air samples taken from oil and gas sites in the Piceance Basin in Colorado in 2008 determined that emissions from well completions, dehydration units, and condensate tanks posed an elevated cancer risk to nearby residents. Similarly, atmospheric measurements collected by researchers at the National Oceanic and Atmospheric Administration concluded that “oil and gas operations in the DJB (Denver-Julesburg Basin) could be the largest source of C6H6 (benzene) in Weld County.”

As oil and gas development continues to expand across the country, strong, national clean air standards are essential to protect public health. EPA’s standards, which build on clean air measures already in place in states with extensive oil and gas activities, such as Colorado and Wyoming, are an important first step in strengthening clean air protections for human health and the environment.

Diesel engine emissions continue to be a problem in the United States even though light cars and trucks have seen 30 years of improved engine standards. Exposure to diesel exhaust can cause lung damage and respiratory problems, exacerbate asthma and existing allergies, and increase the risk of cancer. Given the impact of these emissions on human health, EDF has been pushing for stronger protections from diesel pollution over a decade. By reducing exposure, we can prevent illness, reduce healthcare costs, and save lives.

Emissions and the Houston Barge System

Diesel exhaust in Houston is produced from a number of sources: on and off-road heavy duty equipment and machinery, marine engines, and other equipment used in port operations. In order to implement effective pollution reduction initiatives, we must first properly evaluate and characterize emissions from various sectors within the region. This has proven to be a difficult task, particularly in marine freight and the barge industry.

Freight movement by barge is an important aspect of the Houston economy—and a significant source of air pollution. While maritime transportation is comparably efficient in terms of energy consumption, the sheer volume of marine traffic in Houston makes these emissions an important local health issue.

The Houston Tug & Barge System: A Review of Operations and Opportunities

To help characterize and understand regional maritime emissions, EDF developed a report outlining the profile of barges that operate in the Houston area. The recently released report, “The Houston Barge System: A Review of Operations and Opportunities,” discusses the combustive as well as evaporative emissions associated with barges operating in the Houston region, and identifies opportunities for establishing emissions reduction targets.

Key Areas of Opportunity

Among the findings catalogued in the report, a few opportunities and challenges stand out:

While large oceangoing vessels are a more significant source of marine emissions than harbor tugs, they are regulated primarily by international standards and not subject to local pollution standards.

Given their area and hours of operation, the Houston tugboat fleet offers perhaps the best opportunity for emission reductions on the Houston Ship Channel.

The current fleet of harbor tugs is relatively old and inefficient, and serviced to pre-emissions control standards.

Auxiliary engines are key targets for reduction: they log more hours, require more frequent maintenance, and are easier to replace.

The extensive utilization of each tugboat means that individual improvements can have big payoffs for air quality.

The quality of the air we breathe has a direct impact on our health. The information from this study will help determine the most effective and efficient pollution control strategies for the maritime freight industry and should be used as a guide to develop policies that improve our air quality in Texas.

The United States Court of Appeals in Washington, D.C. heard arguments last week in a group of lawsuits over the Environmental Protection Agency’s (EPA) clean air measures to protect American's health and well-being from the clear and present danger of climate pollution.

(Source: www.bostinno.com)

The Challengers to Clean Air

The state of Texas, along with several large industrial polluters, has challenged EPA's action – even though other states and business allies support EPA's protections. For example, the U.S. auto makers and a dozen states (California, Delaware, Illinois, Iowa, Maine, Maryland, New Mexico, New York, Oregon, Rhode Island, Vermont and Washington) have intervened in defense of EPA's cleaner car standards. EDF has also intervened in defense of EPA's vital protections.

The lead challenger is a group called the Coalition for Responsible Regulation, a group that actively sought to enlist the State of Texas in mounting legal attacks against the EPA's clean air protections. Interestingly, state records show that the Coalition’s board of directors share the same Houston address as the Quintana Minerals Corporation.

Quintana Minerals is the nation’s largest private holder of coal reserves. Its owner, Corbin Robertson Jr., is a contributor to Texas politicians like Governor Rick Perry, Attorney General Gregory Abbott and U.S. Rep. Joe Barton (who memorably apologized to BP for the White House's investigation of the Gulf oil spill) — politicians who are committed to hobbling an EPA that uses rigorous science to regulate harmful pollution.

The EPA Protections Being Challenged

One of the EPA protections facing legal challenge is the Endangerment Finding. To provide a little background, on Dec. 15, 2009, EPA determined that six greenhouse gases endanger the public health and welfare of current and future generations. EPA based this finding on more than 100 published scientific studies and peer-reviewed syntheses of climate change research by the U.S. Climate Change Science Program/U.S. Global Change Research Program, the Intergovernmental Panel on Climate Change, and the National Research Council of the U.S. National Academy of Sciences.

That Endangerment Finding followed the Supreme Court’s landmark 2007 decision in Massachusetts v. EPA. In that decision, the court held that greenhouse gases are air pollutants under the Clean Air Act. The Court then instructed EPA to determine — on the basis of science — whether these gases endanger human health and welfare.

Texas is the second most populous state in the nation, with 25 million residents. Why would a state that has more people in it than that of many states combined fight against clean air protections when other states are intervening on behalf of EPA?

Let’s take this idea further. When you have a lot of people in a state, this means a lot of cars on the road. Indeed, there are over 21 million cars on roads in Texas. At a time when people are increasingly concerned about rising gas prices, the clean car standards will save Texans thousands of dollars at the gas pump by enabling families to drive farther on a gallon of gas, will help break our nation's addiction to foreign oil, and cut dangerous pollution.

The clean car standards established by EPA the Department of Transportation (DOT) are supported by U.S. auto makers, the United Auto Workers, and a dozen states – among others – because they provide significant environmental, economic, and energy security benefits.

There is much at stake for our nation's environment and economy. There is much at stake for our nation's environment and economy. Texas should be a leader in supporting clean car standards instead of a lone cowboy fighting against them.

The APWL is a list of areas in the state where concentrations of harmful pollutants exceed the state’s own health-based screening level guidelines. Some of the APWL areas have been listed for over a decade – this is important as exposure to these toxics may impact human health and may lead to serious health outcomes such as birth defects or cancer. Recognizing the need to reduce air toxics, TCEQ has adopted a formal protocol for remediating these areas.

Figure 1: Active APWL Area Locations, Source: TCEQ

The 2012 report outlines 11 active areas where air toxics were measured consistently at concentrations indicating a level of potential health concern. The report also discusses what the agency is doing to address those areas, which involves focusing investigations on specific facilities, and working with local stakeholders to reduce emissions. As the number of APWL areas has decreased since the first report issued in 2010, it appears that the agency is making some progress in remediating APWL areas. TCEQ proposed delisting Bastrop from the AWPL for hydrogen sulfide, for example, and also reported that benzene levels in Galena Park and Port Arthur have decreased.

We applaud the progress that the agency has made in addressing these hotspot areas, though we recognize that there is much more work to be done. We look forward to working with TCEQ to remediate these areas. We also believe that there may be other areas around the state not currently classified as hotspots (such as Corpus Christi and Midlothian) that are in need of environmental remediation. Let’s make sure that Texas is a healthy place to live!